CORPORATE GOVERNANCE

Newcore subscribes to the highest standards of corporate governance within its own structure and the funds that it manages on behalf of third parties.Newcore has a supervisory board responsible for the business management of Newcore and its governance. This is chaired by Professor Andrew Baum and also comprises Hugo Llewelyn, Managing Director, Tristan Rodgers, Finance Director and Robert Newcombe, non-executive Director in relation to its funds and clients’ accounts, all investment decisions made by the investment team must be ratified by Newcore's investment committee, which comprises Andrew Baum and Hugo Llewelyn.

Stewardship Code

Under COBS 2.2 of the FCA Handbook, we are required to make a public disclosure in relation to the nature of our commitment to the above Code, which was published by the Financial Reporting Council ('FRC') in July 2010.

The Code aims to enhance the quality of engagement between institutional investors and companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and is to be applied by firms on a "comply or explain" basis. The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate.It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle.

The seven principles of the Code are that institutional investors should:

•Publicly disclose their policy on how they will discharge their stewardship responsibilities;
•Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
•Monitor their investee companies;
•Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value;
•Be willing to act collectively with other investors where appropriate;
•Have a clear policy on voting and disclosure of voting activity; and
•Report periodically on their stewardship and voting activities.

Newcore Capital Management Finance LLP does not currently comply with the Code for the following reasons:

•Our investment strategy involves investment in UK real estate and other asset-backed investments.
•We do not currently invest in listed companies in the UK.

Should any of the above factors change, we will review our commitment to the Code at that time and make appropriate disclosure.For further details on any of the above information, please contact Hugo Llewelyn.

Privacy Policy

Our privacy policy sets out what happens to any personal data that you give to us, or any that we collect from you or about you. It applies to all products and services and instances where we collect your personal data.

Who we are

We are a data controller and processor of personal data. If you have any questions about this privacy policy or any information that we hold please contact our data protection officer by post at the address above.

Why and what information we collect about you

We collect and process personal information for compliance with our legal and regulatory obligations, or to fulfil our financial service requirements to you. Personal information includes, but is not limited to, your:

•name;

•date of birth;

•country of residence;

•bank details;

•tax or social security numbers;

•contact details; and

•identification documents (for example passport and driving licence).

Who we share your information with

We may need to share your personal information with the following third parties:

•the funds, companies or partnerships you are invested in;

•our professional advisers or service providers; and

•regulators, law enforcement and government bodies (such as HMRC) where we are required by law to disclose your personal information.

Rights to your personal information

You have the right to:

•ask for information about how your personal information is used;

•ask for a copy of your personal information held;

•ask for any inaccuracies to be corrected or for your personal information to be erased;

•object to any of the ways in which your information is used and ask for information to stop being used; and

•to complain to the Information Commissioner’s Office.

How long we store your information for

We are under a regulatory obligation to retain all personal information for five years. Where an individual is an investor personal information will be kept for up to six years from the date at which they cease to be an investor.

Links to other websites

We link our website directly to other sites. This Notice does not cover external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy notices of any external websites you visit via links on our website.

Changes to our privacy policy

This privacy policy was updated in May 2018. We may change our privacy policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check our privacy policy for changes whenever you visit our website – http://newcorecapital.com

Disclaimer

Newcore Capital Management LLP and Newcore Capital Management Finance LLP, together referred to as Newcore (“Newcore”), provide this website for general information purposes only and does not constitute professional advice. We do not accept any responsibility for loss which may arise from relying on information contained on this site. You must seek professional advice in relation to any area covered by this website in respect of which you have any doubts whatsoever. Newcore does not represent or warrant that the information accessible via this website is accurate, complete or current.

Neither Newcore nor any of its directors, officers, employees or agents, will liable or have any responsibility of any kind for any loss or damage that you may incur in the use of this website.

Whilst Newcore makes all reasonable attempts to exclude viruses from this website, it cannot ensure such exclusion and no liability is accepted for viruses. Thus, you are recommended to take all appropriate safeguards before downloading information from this site.

Newcore reserves the right, at its discretion, to change, modify, add or delete parts of this website. The information or data on this website may be out-of-date, and we make no commitment to update such information or data. Any transactions listed on this website are included as representative transactions and are not necessarily a reflection of overall performance. Newcore cannot and does not guarantee or warrant the accuracy, validity, timeliness or completeness of any references or data on this website.

The material on this website is directed solely at professional clients as defined by the Financial Conduct Authority. The material is not directed at, may not be suitable for and should not be relied on by retail clients. Newcore Capital Management Finance LLP is authorised and regulated by the Financial Conduct Authority under number 582190.

The terms and this disclaimer and any claim based on the use of information from this website shall be governed by the laws of England and the parties submit to the exclusive jurisdiction of the Courts of England and Wales.

The information provided on our website is not provided to and may not be used by any persons or entity in any jurisdiction where such would be contrary to applicable laws, rules or regulations of any governmental authority or regulatory or self-regulatory organisation or where Newcore is not authorised to provide such information or services.

This website has been produced by Newcore and no part may be reproduced in any manner without the written permission of the same.

Cookie policy

Our cookie policy describes how we may collect and use information you provide when you visit this website.

Who we are

We are a data controller and processor of personal data. If you have any questions about this cookie policy or any information that we hold please contact our data protection officer by post at the address above.

What cookies are and why we use them

A cookie is a small text file which may be placed onto your computer or device when you access our website. We use cookies to help our website work more efficiently, as well as improve your experience of using it.

How to disable cookies

You can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.

Changes to our cookie policy

This cookie policy was updated in May 2018. We may alter our cookie policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check our cookie policy for changes whenever you visit our website – http://newcorecapital.com